March 22, 2010

Mr. Clint Jones or Mr. Phil Ford

Federal Aviation Administration

Transport Aircraft Directorate, ANM-100

1601 Lind Avenue, SW

Renton, WA 98057-3356

SA1265NE Single AC Config

PETITION FOR EXEMPTION

The Leading Edge Group, LLC (LEG), as FAA Supplemental Type Certificate (STC) holder of

SA 1265NE requests FAR compliance relief and submits this Petition for Exemption (PIE) to FAA

rulemaking established under 14 CFR Sect. 26.47{c) & (e)(2).

LEG petitions the US Government for engineering task relief on a Single Configuration of

SA1265NE for (1) 8737-269 aircraft, SN 21206 with LEGlpats Auxiliary Fuel System (AFS) in VIP

LOPA Configuration.

8737-200 (Reg. C-GWJK) is operated in private VIP service by NewJet Engine Services

1. This SN contains a VIP stateroom and is configured for HOS service.

2. This SN operates exclusively in private service.

3, This SN is listed only on Canadian foreign registry.

4. This SN will require extensive engineering changes for a deck plan (LOPA) to be

suitable for EASA or US commercial revenue service under FAR 121 (125 or 135),

5, Responsive engineering resources of the FAA can be conserved and financial relief to

the US Govt. can be realized on behalf of the DAH; upon timely approval of this PIE,

6, Air safety will not be adversely impacted given the Operators attention to FAR

compliance with a limited VIP flight operation.

In the event this SN is transferred to a third party and an interior reconfiguration (LOPA) is

completed, a current airframe survey to include #4 changes can be reviewed and specific

airframe load and inspection analysis (DTE lOTI) due FAA under the Aging Aircraft Safety Rule

for the AFS (and the attach points) can be completed in accordance with FAR 26.47(c) and (e)(2),

Sincerely,

TH~?J G7GROUP,LLC

Capt. Karl n, Managing Director

AirSpee

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Corpotate office 3425 GltI!lon Point- Kitk!.lnr:lWJS/If/lgton 98033 Main (425) 576-403"0
ASE 100325-17 FRPE

PUBLIC COMMENT

www.airspeed.us.com

March 25, 2010

Federal Register Petition for Exemption submittal for public comment:

The Leading Edge Group, LLC (LEG), as FAA Supplemental Type Certificate (STC) holder

of SA126SNE requests FAR compliance relief and submits this Petition for Exemption

(P/E) to FAA rule making established under 14 CFR Sect. 26.47(c) & (e)(2).

LEG petitions for US Govt. engineering task relief on a single Configuration of SA126SNE

for 8737-269 series aircraft, with LEG/pats Auxiliary Fuel System (AFS) in VIP passenger

cabin (LOPA) deck plans.

Boeing SNs 21206 :

1. This SN contains a VIP stateroom and is configured for HOS service.

2. This SN operates exclusively in private or Head of State (HOS) service.

3. This SN is listed on foreign Registry.

4. This SN will require extensive engineering changes for a deck plan (LOPA) to

be suitable for EASA or US commercial revenue service under FAR 121.

5. Responsive engineering resources of the FAA can be conserved and financial

relief can be realized on behalf of the DAH and US Government; upon timely

approval of this PIE.

6. The Operator nor STC holder are not able to determine if modifications to the

AFS loading points on this airframe have been altered, AFS brackets removed or,

if the AFS attach points have been adapted for other purposes; requiring in

themselves new lCAs.

7. Operator disclosure and DAH-onboard AFS survey of the aircraft is required to

submit useful engineering to FAA that is relevant to SN existing condition.

8. It is the position of the STC holder that air safety will not be adversely

impacted given this SN has limited private use and with over 3D-years of

airframe age, will likely never return to commercial FAA/EASA air carrier service.

In the event this SN is transferred to a third party and an interior reconfiguration (LOPA)

is completed, a current airframe survey to include #6 changes can be reviewed and

specific airframe load and inspection analysis (DTE lOTI) due FAA under the Aging

Aircraft Safety Rule for the AFS (and the attach points) can be accomplished in

accordance with FAR 26.47(c) and (e)(2).

Thank you.

Karl Seuring, Managing Director

The Leading Edge Group, LLC

Kirkland, WA 98033

Corpor:JfeoU;ce 3425 C~rJ1lonPoint Kirk/~n4 W~5hington 98033 M:ufI (425) 576-4030